In the matter of 1996 Telecommunications Act, Analysis of FCC Proceeding on Universal Service, Notice of Proposed Rule Making, Federal-State joint Board on Universal Service
Federal-State joint Board on Universal Service FCC 96-93
CC Docket No. 96-45
To: The Federal-State joint Board on Universal Service
COMMENTS OF THE ALASKA LIBRARY ASSOCIATION
Sec. II. Goals and Principles of Universal Service Support Mechanisms
6. Comment on NPRM Question 6 regarding how best to incorporate the variation among urban users according to the demographic characteristics of consumers located in a given urban area -- specifically how to incorporate that variation in the use of urban area service as a benchmark for comparative purposes. As Alaska has the highest percentage of its population classified as urban and the largest percentage of its land mass classified as rural, isolated, the Alaska Library Association suggests that service to all of the citizens of the state of Alaska be based on those offered to the highest income residential area in Anchorage. In addition, the Alaska Library Association suggests that if the majority of U.S. subscribers have services available which are not offered in Anchorage, Alaska then those services be included in state's benchmark.
9. Comment on NPRM Question 9. "[The Commission] interprets the statutory language of Section 24 (c) (1) as manifesting Congressional intent that the joint Board and the Commission consider all four criteria when deciding what services to-support through Federal universal service. [The Commission] interprets this language, however, -- particularly use the use of the word "consider" -- to allow the joint Board and the Commission to include services that do not necessarily meet all of the four criteria.
a. It is important that these four criteria be applied independently. In Alaska it is quite probable that telecommunications services deemed essential by a majority of schools and libraries for educational purposes may not be "subscribed to by a substantial majority of residential customer." It is entirely possible that the school (school district) may be the largest purchaser of telecommunications services in an area.
b. Features Essential to Education. The Alaska Library Association is convinced that this determination must be made by school districts and publicly funded libraries through their individual and collective purchases of telecommunications services offered to them at discounted rates.
Section III. Support for Rural, insular, and High-Cost Areas and Low-Income Consumers.
16. Comment on NPRM Question 6 regarding "core services." The following basic services should be included among those core services that are included in the definition of universal services for education purposes with the 'point of presence being every school office, classroom and publicly funded library in America: (1) voice grade access to the public switched network, with the ability to place and receive calls, (2) touch-tone; (3) single party service; (4) access to emergency services; and (5) access to operator services.
17. Comment on NPRM Question 7 regarding additional services that meet the criteria of Section 24 (c) (1) and should be among the services that should receive universal service support. The Alaska Library Association believes the definition of those "additional" services is included in the Telecommunications Act of 996 under the definition of "Advanced Telecommunications Capability." The term is defined without regard to any transmission media or technology, as high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications using any technology. By this definition and the criteria specified in Section 2 4 (c) (), frame relay service, voice mail, high-speed Internet access, electronic mail accounts and high speed transmission and broadband telecommunications services, should also be considered as additional basic service for educational and library purposes.
3 . Comment on NPRM Question 3 regarding a specific proxy model by several telecommunications carriers. The Alaska Library Association is glad to see that Hawaii and Alaska are specifically exempt from the model as it is clear that cost differentials are so out-of-scale for these states that one model would not fit. The Alaska Library Association would wish to guarantee that any model take into consideration the real cost of providing service to rural Alaska and factor costs accordingly. Based on Alaska's telecommunications history we can be assured that costs for rural Alaska will be considerably higher and a single national model would not be adequate.
33. Comment on NPRM Question 33 regarding a proxy model that incorporates data showing the location of actual residential and business customers. It should be noted that in certain rural, insular areas of Alaska school districts may be the largest consumers of telecommunications services. In these areas a proxy model considering only residential and business customers would not be accurate.
34. Comment on NPRM Question 34 questioning census block groups as the best geographic units for developing a proxy model. The Alaska Library Association is concerned that census blocks may not be the best geographic unit for developing a proxy model as they have no relationship between a network which exists, or may be proposed, and associated costs.
35. Comment on NPRM Question 35 soliciting comment on a competitive bidding process to set the level of subsidies required in rural, insular, and high cost areas. It is important to remember that Alaska does not now have and will not have in the foreseeable future , competition in all areas of the state. The Alaska Library Association does not believe a competitive bidding process would be functional in this state for several years. The Alaska Library Association knows that schools, libraries and health care centers will not have universal service, no matter how many discounts are offered or how low rates are structured, if the telecommunications infrastructure is not in place.
47. Comment on NPRM Question 47, Section 24(e)(3). The Alaska Library Association is certain that populated areas in Alaska exist where no common carrier will elect to provide the services supported under the Act. The Library Association strongly supports the development of a cooperative program between the FCC and the State Commissioners to ensure that all areas which have schools, libraries and health care centers receive equitable services.
69. Comment on NPRM Question 69 seeking comment on whether it would be useful to collect and publish certain basic information regarding technical performance levels of carriers subject to FCC Jurisdiction. In order to fairly and rapidly implement the 996 Telecommunications Act consumers must have access to a full range of information regarding carriers and their capabilities. Disclosure of proprietary information could be avoided through publication of aggregated data.
Section IV. Schools, Libraries, and Health Care Providers
79. Comment on NFRM Statement 79 regarding a February 1996 study, Advanced Telecommunications in the U.S. Public Elementary and Secondary Schools. The Alaska Library Association confirms that this survey instrument must be updated in order to compile up-to-date and accurate information.
80. Comment on NPRM Statement 80 regarding comment on what functionalities should be supported through universal service mechanisms for schools and libraries. Eligible schools, classrooms, and libraries must have access to all available advanced telecommunications services at discounted rates. The Alaska Library Association states that it is necessary for the determination of service needs to be made by school, classroom, and library consumers. Alaska has 84 public libraries. Of these, 32 serve populations which range from to 499 residents, another 8 serve populations of between and 999. 8 of the state's public libraries operate on a total annual budget under $,. Another 28 have budgets which range between $ , and $24, dollars annually. The next 6 public libraries have operating revenues of between $2, and $99,999 annually. Only 34 of the State's libraries are on a road system. The remaining can easily be classified as rural. It is clear that the functionalities supported through universal service must not discriminate in determining access to these libraries. The Alaska Library Association believe that "geographic area" should be defined as the entire state for the purposes of Section 24(h)(1)(B)..
85. Comment on NPRM regarding the proposal that any person qualified under State or local law to order telecommunications services for schools or libraries be deemed capable of making a 'bona fide Request" for service. it should be remembered that the case of schools and public libraries, the entity making the request on behalf of the in school or library may be a third party, ineligible for service, such as state or local government telecommunications department. In such a case, the school or library could certify that the services have been order for their use.
86. Comment on NPRM regarding the resale of 'telecommunications services and network capacity' provided to schools and libraries through universal service support mechanisms. This provision provides a major concern for Alaska. In regard to eligible libraries in Alaska, criteria under Title III of the Library Services and Construction Acts allows any library, regardless of type, to participate in the program. Grants are given to academic libraries. We presume postsecondary institutions are not eligible for universal service support under the Telecommunications Act. It is essential to allow cooperative projects, which include academic institutions. Alaska provides a clear example of shared services. The most innovative and far reaching public access project in Alaska is SLED, the Statewide Library Electronic Doorway, a shared project of the Alaska State Library and the University of Alaska Fairbanks Library. SLED became available at no charge to Alaskans in more than 4 communities in April, 994. SLED is an easy-to-use World Wide Web site connecting people to online information. 6 % of the state's total population lives in Anchorage, Fairbanks and Juneau, so the project funds direct high-speed network connections to the public libraries in these communities. SLED is also available through the Internet, via dial-up to some local library systems, and via local dial-ups on AT&T Alascom's X.2 network, AlaskaNet. SLED then pays by the hour for each AlaskaNet connection.
SLED can reach approximately 87% of Alaska's citizens. The University of Alaska Fairbanks Library provides the service which is funded by the State Library. The largest portion of the bill is centered on reimbursement for telecommunications costs. The provision of SLED services would not be possible without a cooperative arrangement with the University of Alaska.
As it appears legislative funding for SLED may be reduced in FY97, the State Library may be forced to charge a fee to libraries wishing to participate in SLED. The act must allow these cooperative ventures without interpretation as resale. In Alaska quality service will depend on the cooperative efforts of schools, libraries and health care providers together and with their greater communities..
Another cooperative example is SeakNet (the Southeast Alaska Internet Access Project). It is funded by NTIA to a partnership that includes the Alaska State Library, University of Alaska Statewide Office of Network Services, the Southeast Regional Resource Center and the communities of Gustavus, Haines, Hoonah, Kake, Ketchikan, Sitka , and Wrangell. The grant will establish seven pilot sites to expand access and for a Community network. SLED and access to the Internet will be available without charge through the libraries and local modern dial-up. Individual email accounts for access from home or office will be available for a fee through an Internet server managed by the University of Alaska. Half of the email fee will go to the University to support telecommunications, the other half will be used to develop a Sustainability Fund for the ongoing operation of SeakNet.
Again, the entire premise of the SeakNet grant is that in small Alaskan communities, no one entity can afford the telecommunications costs for high-speed access (even 56K is considered "high-speed" in Alaska as many of our communities have only 9600 baud access and many others have no access at all) If the school, the library and, for example, the local state Fish and Game office share a frame relay circuit into a community, we would certainly not want the school and the library to be denied universal service support because one partner is a general government entity. Perhaps universal service support could be levied on a percentage of traffic basis on a shared network.
Alaska also has a strong tradition of consortium libraries. These libraries represent k 2 school and public library cooperative, university and public library partnerships and in Juneau a state, university, public and high school cooperative. In the case of Juneau, the State is the telecommunications provider.
The Act's requirement that discounted telecommunications services and network capacity should not be resold should not be interpreted to prohibit reasonable user fees for special applications or services within a school or public library. The Alaska Library Association expresses concern with the resale provision and its impact on the ability of schools, libraries and health care centers to partner with the State of Alaska. A key question will be who should provide the support for universal service.
These comments are presented on behalf of
The Alaska Library Association
P.O. Box 884
Fairbanks, Alaska 9978
Mary Ellen Emmons, President